CFTC Extended Relief With Respect To Dodd-Frank Effective Dates For Derivatives

On October 18, 2011, the Commodity Futures Trading Commission ("Commission") voted 5-0 to propose an order¹ (the "Proposed Order") extending the temporary exemptive relief provided under the Commission's July 14, 2011 order ("July Final Order") to delay the effective date of most of the new requirements under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank").² Most of the requirements of Title VII of Dodd-Frank were originally due to take effect on July 16, 2011. For many requirements that depend on additional rulemaking (including key definitions), the July Final Order delayed effectiveness until the earlier of the effective date of the final rule further defining the relevant term or December 31, 2011. The Proposed Order amends the July Final Order by extending the temporary relief until the earlier of the effective date of the final rule further defining the relevant term or July 16, 2012.